2.3 Traveling, loading and leaving the truck
Paragraphs (m), (n) and (o) of 1910.178 are the operating manual OSHA wrote: how to travel, how to pick up and set down, and what has to be true before you get off. They read like common sense until you notice how many of them describe an incident somebody had.
1 Traveling: speed, distance, sight lines
Paragraph (n) opens with the rules of the road. (n)(1): all traffic regulations observed, including authorized plant speed limits, a safe distance of approximately three truck lengths from the truck ahead, and the truck kept under control at all times. (n)(8): under all travel conditions, operate at a speed that permits stopping in a safe manner. (n)(15): reduce speed before turning and turn the wheel smoothly rather than sharply.
Then the sight-line rules covered in Part 1 — (n)(4) horn and slow down at cross aisles and obstructed views, load trailing when it blocks the view; (n)(6) look in the direction of travel. And two that catch people out: (n)(3) forbids passing another truck traveling in the same direction at an intersection, blind spot or other dangerous location, and (n)(9) forbids stunt driving and horseplay — which sounds quaint until you have watched somebody spin a truck for an audience.
2 Grades, ramps and the rule people get backwards
(n)(7) requires grades to be ascended or descended slowly, and then gives the rule that matters: when ascending or descending grades in excess of 10 percent, loaded trucks must be driven with the load upgrade. On all grades the load and the load engaging means must be tilted back if applicable, and raised only as far as necessary to clear the road surface.
"Load upgrade" means the load points uphill, whichever way the truck is pointing. Going up a 12 percent ramp with a pallet, you drive forward. Coming back down the same ramp with that pallet, you drive in reverse, load still uphill. The reason is the load moment: with the load downhill, the fulcrum shifts and the load can pitch out over the forks.
Two more of (n)'s items are pure warehouse: (n)(10) requires slowing down for wet and slippery floors, and (n)(5) requires railroad tracks to be crossed diagonally where possible and forbids parking closer than 8 feet from the center of a track.
3 Picking up and setting down
Paragraph (o) is short and every line describes a way loads fall off.
| Paragraph | Requirement |
|---|---|
| (o)(1) | Only stable or safely arranged loads are handled; use caution with off-center loads that cannot be centered. |
| (o)(2) | Only loads within the rated capacity of the truck are handled. |
| (o)(3) | Long or high loads, including multiple-tiered loads, that may affect capacity must be adjusted. |
| (o)(4) | Trucks equipped with attachments are operated as partially loaded trucks even when not handling a load. |
| (o)(5) | Place the load engaging means under the load as far as possible, then tilt the mast carefully backward to stabilize the load. |
| (o)(6) | Extreme care when tilting, particularly high tiering. Tilting forward with the forks elevated is prohibited except to pick up a load or to deposit a load over a rack or stack; when stacking, use only enough backward tilt to stabilize. |
(o)(4) is the sleeper. A clamp, a rotator or a set of extensions counts as load all the time — so an "empty" truck with attachments is already partway to its capacity, and the operator who drives it like an empty machine is wrong from the first corner.
4 Unattended means something specific
This is the paragraph most often quoted wrongly, so here it is exactly. (m)(5)(i): when a truck is left unattended, the load engaging means must be fully lowered, controls neutralized, power shut off and brakes set — and wheels blocked if the truck is parked on an incline.
(m)(5)(ii) defines it: a truck is unattended when the operator is 25 feet or more away from a vehicle that remains in view, or whenever the operator leaves the vehicle and it is not in view. (m)(5)(iii) covers the in-between case: dismounted but within 25 feet and the truck still in view — forks fully lowered, controls neutralized, brakes set to prevent movement. Power may stay on in that case; everything else still applies.
5 Overhead guard, backrest, headroom and riders
Four more items of paragraph (m) describe the protective hardware and the two prohibitions everyone knows and somebody breaks weekly.
- (m)(9) — an overhead guard must be used as protection against falling objects, with the standard's own honest caveat: it is intended to protect against the impact of small packages, boxes and bagged material representative of the job, not to withstand the impact of a falling capacity load.
- (m)(10) — a load backrest extension must be used whenever necessary to minimize the possibility of the load or part of it falling rearward.
- (m)(8) — sufficient headroom under overhead installations, lights, pipes and sprinkler systems. This is the paragraph that a raised mast breaks.
- (m)(3) — unauthorized personnel must not ride on trucks; where riding is authorized, a safe place to ride must be provided. And (m)(4) prohibits arms or legs between the uprights of the mast or outside the running lines of the truck.
Add (m)(14), which belongs to Part 5 as much as here: fire aisles, access to stairways and fire equipment must be kept clear. A truck parked in front of an extinguisher is a violation of the forklift standard, not just of the fire one.
6 Elevating people, and where general industry goes quiet
Here is a genuine gap worth understanding. In construction, 1926.602(c)(1)(viii) spells out what is required when a truck is used to elevate personnel: a safety platform firmly secured to the lifting carriage or forks, a means for the people on the platform to shut off power to the truck, and protection from falling objects as conditions require.
1910.178 contains no equivalent paragraph. That does not make it acceptable to lift someone on bare forks or on a pallet — it means the duty comes from elsewhere: 1910.28(b)(1)(i), because a platform 4 feet above a lower level is a walking-working surface with an unprotected edge; the manufacturer's instructions, which are pulled in as training content by 1910.178(l)(3)(i)(M); and the General Duty Clause. Order pickers, where the operator's platform rises with the forks, are designed for the job and come with a manufacturer requirement for a body harness and tether — that is the machine to use when someone has to go up.
- (n)(1) and (n)(8): plant speed limits, about three truck lengths of following distance, and a speed you can stop from.
- (n)(7): on grades over 10 percent, drive loaded trucks with the load upgrade; tilt back and raise only enough to clear.
- (o)(2) and (o)(4): only loads within rated capacity — and a truck with attachments is a partially loaded truck at all times.
- (o)(6): no forward tilt with elevated forks except to pick up or to deposit over a rack or stack.
- (m)(5): unattended = 25 ft or more away in view, or out of view at all. Forks down, neutral, power off, brakes set.
- General industry has no personnel-platform paragraph; 1910.28(b)(1)(i) and the manufacturer's manual govern instead.
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